Harrison v. Bittler

72 Va. Cir. 7, 2006 Va. Cir. LEXIS 314
CourtLoudoun County Circuit Court
DecidedMarch 2, 2006
DocketCase No (Law) 32674
StatusPublished
Cited by1 cases

This text of 72 Va. Cir. 7 (Harrison v. Bittler) is published on Counsel Stack Legal Research, covering Loudoun County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Harrison v. Bittler, 72 Va. Cir. 7, 2006 Va. Cir. LEXIS 314 (Va. Super. Ct. 2006).

Opinion

By Judge James H. Chamblin

This case came before the Court on February 3,2006, for argument on the Demurrer of the Defendants Brian Gaquin and Denise Gaquin to the Motion for Judgment filed on October 18, 2004, by the Plaintiff, Blake Harrison. After consideration of the Memorandum in Support of Defendants Brian and Denise Gaquin’s Demurrer (filed January 27,2006), the Plaintiffs Response to the Demurrer of Denise Gaquin and Brian Gaquin (filed January 30,2006), and the argument of counsel on February 3,2006, the Demurrer to Counts II, III, and IV of the Motion for Judgment is sustained. There is no need to address the Demurrer as it relates to the punitive damages and attorney’s fees claims. The Motion for Judgment is dismissed with prejudice as to the Gaquins.

[8]*8Harrison is not granted leave to amend his Motion for Judgment because he cannot in my opinion state a cause of action against the Gaquins under the circumstances of this case as alleged.

As this case is before the Court on a demurrer, any decision thereon must be based on several well-established general principles. A demurrer only tests the legal sufficiency of the claims stated in the pleading challenged. Dray v. New Market Poultry Products, Inc., 258 Va. 187, 189 (1999). A demurrer admits the truth of the facts contained in the pleading to which it is addressed, as well as any facts that may be reasonably and fairly implied and inferred from those allegations. Cox Cable Hampton Roads, Inc. v. City of Norfolk, 242 Va. 394, 397 (1991). However, a demurrer does not admit the correctness of the pleader’s conclusions of law. Fox v. Custis, 236 Va. 69, 71 (1988).

Demurrer to Count II: Negligence of Brian and Denise Gaquin

The Gaquins demur to Count II of the Motion for Judgment on the ground that it does not allege a breach of legal duty owed by them to Harrison, Plaintiff, or Bittler, the other defendant. I agree with the Gaquins.

Whether a legal duty exists is a pure question of law. Yuzefovsky v. St. John’s Wood Apartments, 261 Va. 97, 106 (2001); Burns v. Johnson, 250 Va. 41, 45 (1995). If the allegations are legally sufficient to establish a duty as a matter of law, then it becomes a matter for the jury, upon the evidence, to determine whether the duty has been breached or performed. Acme Markets, Inc. v. Remschel, 181 Va. 171, 178 (1943).

Virginia recognizes the general rule that a person has no duty to control the conduct of third persons. In doing so the Virginia Supreme Court recognizes the principle set forth in the Restatement of Torts (Second) § 315 (1965) as follows:

There is no duty so to control the conduct of a third person as to prevent him from causing physical harm to another unless:
(a) a special relation exists between the actor and the third person which imposes a duty upon the actor to control the third person’s conduct, or
(b) a special relation exists between the actor and the other which gives to the other a right to protection.

See, e.g., Marshall, Administratrix v. Winston, 239 Va. 315, 318 (1990);Fox v. Custis, 236 Va. 69, 74 (1988); Klingbeil Management Group Co. v. Vito, 233 Va. 445, 447 (1987); Gulf Reston Inc. v. Rogers, 215 Va. 155, 158 (1974).

[9]*9The foregoing general rule is especially the case when a third person commits acts of assaultive criminal behavior because criminal conduct cannot reasonably be foreseen. Marshall, 239 Va. at 318. The policy considerations underlying this rule are obvious. There is generally no duty to act as an insurer for the safely of others. A landowner is not required to act as a police officer. In Virginia strict liability is the rare exception. Any duty on a landowner would necessarily involve an additional expense.

Restatement § 315(a) does not apply to this case because Harrison does not argue that the Gaquins had a duty to control Bittler’s conduct. However, Harrison argues that the facts as alleged in the Motion for Judgment show that a special relationship exists between the Gaquins and him, which imposes a legal duty on them to protect him under Restatement § 315(b). I do not agree.

Harrison was a social guest on the property of the Gaquins. He was a licensee. Bradshaw v. Minter, 206 Va. 450, 452 (1965) (a social guest “is an invitee who is not an invitee” and “the great weight of Anglo-American authority classifies him as a bare licensee, even though he was expressly invited. ”)

Counsel have not cited, and I have not found, any Virginia authority on the specific duty of a social host (licensor) to a social guest (licensee) as to harm from the assaultive criminal behavior of third persons on the property of the social host (licensor). However, there are Virginia cases including some of the ones cited above, that concern the duty owed by an occupant of land to an invitee.

As a general rule, in Virginia there is no duty on an owner or occupier of land to warn his invitees of, or protect them against, harm from the criminal act of a third party while the invitee is on the premises of the owner or occupier. Dudas v. Glenwood Gulf Club, 261 Va. 133, 139 (2001); Gupton v. Quicke, 247 Va. 362, 363 (1994); Wright v. Webb, 234 Va. 527, 530 (1987).

However, as fully explained in Yuzefovsky, there are some narrow exceptions to the general rule of no duty, but the Virginia Supreme Court has “rarely found the circumstances of the cases under review to warrant application of these exceptions.” 261 Va. at 106.

Yuzefovsky also sets forth the general analysis applicable for determining whether an exception to the general rule applies. First, a plaintiff must establish that there is a special relationship between him and the defendant or between the defendant and the third party criminal actor. The special relationship can arise from either one recognized as a matter of law, such as between an innkeeper and his guest, or from the factual circumstances of a particular case. Second, a plaintiff must establish the special relationship creates a duty of care, such as to warn and/or protect him, as a result of the [10]*10particular circumstances of the special relationship, including the known or reasonably foreseeable danger of harm to him from the criminal acts of a third party. So it is a fact-specific determination. Also, the imposition of the duty does not depend upon foreseeability alone, as consideration must be given to the magnitude of the burden of guarding against harm to the plaintiff and the consequences of placing the burden on the defendant. See Wright, 234 Va. at 531; Gulf Reston, 215 Va. at 159.

As to business owner and invitee and landlord and tenant, there is no duty to take measures to protect an invitee against criminal assaults unless the business owner or landlord knows that criminal assaults against persons are occurring, or are about to occur, on the premises which indicate an “imminent probability of harm” to an invitee. Wright, 234 Va. at 533. As expressed in Thompson v. Skate America, Inc., 261 Va. 121, 130 (2001), “imminent probability of harm” is merely a heightened degree of foreseeability of the harm, Glenwood Golf Club makes it clear that there is no distinction between a duty to warn and a duty to protect; the same standard applies. 261 Va. at 141.

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Bluebook (online)
72 Va. Cir. 7, 2006 Va. Cir. LEXIS 314, Counsel Stack Legal Research, https://law.counselstack.com/opinion/harrison-v-bittler-vaccloudoun-2006.